Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Extended period of limitation of five years: Mere non-disclosure of receipts in the service tax return does not automatically mean there was an intent to evade payment of service tax. Suppression of facts has to be willful and with an intent to evade tax, as held by the Supreme Court. In this case, the department had already scrutinized the records earlier, and the show cause notice was based on entries available in the balance sheet. Therefore, the impugned order invoking the extended period was set aside, and the appeal was allowed.
Extended period of limitation of five years: Mere non-disclosure of receipts in the service tax return does not automatically mean there was an intent to evade payment of service tax. Suppression of facts has to be willful and with an intent to evade tax, as held by the Supreme Court. In this case, the department had already scrutinized the records earlier, and the show cause notice was based on entries available in the balance sheet. Therefore, the impugned order invoking the extended period was set aside, and the appeal was allowed.
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